NEWS

PCS team member Dale Zahn will be attending the TRE Spring 2013 Standards and Compliance Workshop that is being held in Austin, TX, May 22 - May 23, 2013.  Dale will be happy to share with you what PCS is doing in the industry and how we can help you with your NERC Reliability Compliance needs.

Greetings from Proven Compliance Solutions Inc. (PCS)!

PCS wants to remind all of our clients and business partners that NERC will begin enforcing a minor change in the PRC-005 (Protection System Maintenance and Testing Program) world on April 1, 2013.  (Somehow, we think the date of enforcement is somewhat amusing.)  On that date, the new approved definition of a Protection System will take effect, adding battery chargers to the programs required of Transmission Owners, Generator Owners, and Distribution Providers.  This new definition appears in the NERC Glossary of Terms (see http://www.nerc.com/files/Glossary_of_Terms.pdf) and is provided here for clarity:

Protection System –

  • Protective relays which respond to electrical quantities,
  • Communications systems necessary for correct operation of protective functions,
  • Voltage and current sensing devices providing inputs to protective relays,
  • Station dc supply associated with protective functions (including batteries, battery chargers, and non-battery-based dc supply), and
  • Control circuitry associated with protective functions through the trip coil(s) of the circuit breakers or other interrupting devices.

There are several subtle changes, some of which merely answer existing questions regarding the scope of equipment, but the addition of battery charger and non-battery-based dc supply is of immediate concern.

All Transmission Owners, Generator Owners, and Distribution Providers must update their specific PRC-005 program documentation prior to April 1, 2013 to incorporate the battery chargers and non-battery-based dc supply.  This means that your program document, in an approved form, must include a section on these devices and include maintenance and testing intervals and their basis (R1.1), as well as a summary of maintenance and testing procedures (R1.2).  We believe this will require a complete listing of all battery chargers associated with protective relay applications in your facilities as well as a search of all pertinent manufacturers’ instruction manuals, leaflets, and letters.  This preliminary work will form the required basis for any identified intervals as well as determine the basic maintenance procedures to be included.  (The implementation plan, found at http://www.nerc.com/docs/standards/sar/Project_2007-17_Implementation_Plan_for_Revised_Definition_clean_20101028.pdf, allows one complete ‘maintenance cycle’ for the devices before R2 of the standard will be enforced.)

Please let us know if you have any questions.  While we (and the industry) consider this change to be minor in nature, we note that all TOs, GOs, and DPs will be held accountable for this new definition beginning on the specified date of April 1, 2013.  We interpret this to mean that if your program does not have the required devices included as of the 4/1/2013 date, you will have a reportable violation of the standard from that day until they are added.

Thanks and best wishes from all of PCS.

PCS team members Crystal Musselman and Anita Swanson will be attending the WECC Compliance User Group meetings and WICF Meetings January 28-29, 2013 at the Phoenix Marriot Hotel & Convention Center (Mesa, Arizona).  Dale Zahn and Jason Phillips will be there as well with big news about a new PCS offering, and can be found at the PCS information table.  Stop by and say hello.  We’re all happy to share what PCS can do to help you and your company with your reliability compliance needs.  Ryan Carlson will also be there to attend the CIP User Group meeting on January 30th.  We look forward to seeing you in sunny Mesa!!

 

Proven Compliance Solutions (PCS) places high emphasis on the need for buyers and/or sellers, along with bonding agencies to perform this same due diligence with respect to the status of an entity’s NERC compliance.

Due Diligence refers to an investigation or audit of a potential investment and serves to confirm all material facts in regards to a sale. Likewise, Due Diligence also indicates the amount of care a reasonable person or entity should take before entering into an agreement or a transaction with another party. Until recently, the emphasis for any power acquisition was based primarily on the physical condition of the facilities and the financial payback of the investment which includes extensive risk assessment. One aspect of transaction risk that in many cases has not been identified is the due diligence associated with an analysis of NERC compliance and the potential penalties associated with non-compliance. Proven Compliance Solutions (PCS) places high emphasis on the need for buyers and/or sellers, along with bonding agencies to perform this same due diligence with respect to the status of an entity’s NERC compliance. Finding the right resource to perform this service is essential and PCS is ready to show you why it is a leader in the industry.

THE SELLER:
As part of their “Asset Marketability Plan,” existing entities engage PCS to identify areas of non-compliance and to provide solutions and support in issue resolution, if any. When completed, PCS provides recommendations for improvement that will reflect a robust compliance program. This increases the marketability of the asset and is a key component to supporting a potential sale.

THE BUYER:
For Entities looking to expand their portfolio, often times in multiple regions or in regions that have are not part of their current portfolio, PCS represents their interests by determining the compliance status of the facility(s) under purview in the new region By compiling and analyzing the available documentation and supporting evidence, PCS can effectively and expertly opine on the current state of compliance while offering comment on the probable cost associated with achieving and sustaining auditable compliance.

THE BONDING AGENCY:
Assurance that NERC Compliance risk is not transferred to the buyer, or is mitigated to a manageable level, is a component as defined by many Bonding Agencies and Financial Services Providers. Acquisitions involving high risk or high probability of violations can weigh negatively and carry costs.

WHY PCS:
PCS understands the value of high quality operational and engineering processes necessary to drive compliance. We apply a history of true compliance expertise to every aspect of the services we provide and draw upon decades of actual operating experience in delivering an accurate assessment of an entity’s state of compliance.

PCS team members Crystal Musselman and Anita Swanson will be attending the WECC Compliance User Group meetings and WICF Meetings January 28-29, 2013 at the Phoenix Marriot Hotel & Convention Center (Mesa, Arizona).  Dale Zahn and Jason Phillips will be there as well with big news about a new PCS offering, and can be found at the PCS information table.  Stop by and say hello.  We’re all happy to share what PCS can do to help you and your company with your reliability compliance needs.  Ryan Carlson will also be there to attend the CIP User Group meeting on January 30th.  We look forward to seeing you in sunny Mesa!!

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